Answer:
a. MMT is formed as a C corporation.
Mickey and Mickayla will not recognize any gain, while Taylor must recognize $100,000 as ordinary income. Mickey and Mickayla's exchange classifies under §351, but Taylor's doesn't.
b. MMT is formed as an S corporation.
Mickey and Mickayla will not recognize any gain, while Taylor must recognize $100,000 as ordinary income. Mickey and Mickayla's exchange classifies under §351, but Taylor's doesn't.
c. MMT is formed as LLC.
Mickey and Mickayla will not recognize any gain, while Taylor must recognize $100,000 as ordinary income. Mickey and Mickayla's exchange classifies under §721, but Taylor's doesn't.
Explanation:
Basically §351 and §721 are very similar except that one applies to corporations and the other applies to partnerships and LLCs. No gain will be recognize when assets are transferred in exchange for equity, and the people involved in the exchange can control the company.